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Common Boiler Problems, Part 9: Grandfathering Old Equipment

Jurisdictional inspectors often have their hands tied when it comes to what they can ask someone to do. What they are inspecting is often limited by exactly the letter of the law. For example, in many cases they can only evaluate equipment based on its code compliance for when it was installed. Code compliance is not retroactive. Codes usually change on three-year cycles, but compliance with new versions is optional. Safety codes have committees and evolve for a reason. It’s because the technical world finds out how to do things better over time. The difference between what is installed and what is current code is called a gap. Conducting gap analysis on equipment as it is installed can provide a road map for getting current and maximizing safety.

When a jurisdictional inspector walks away saying everything passed, managers and others in a position of authority have a certain peace of mind – even about 40–year old equipment that requires many manual steps to operate safely and puts their site at serious risk of improper manual start-up or shutdown daily. These managers need to learn that being technically “in compliance – but nowhere near the current code’s level of safety" – is not a moral victory.

Consider also that unless you are in a state that mandates ASME CSD-1 or NFPA 85 compliance, inspections rarely address gas trains and/or fuel system issues. Interlock and gas train testing is usually assumed to be a responsibility of the owner in these states. You can imagine that the level of compliance with these little known testing requirements is much less in states where the issue of combustion control testing is not even on the table.


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